- Generally yes, with conditions: Japan, the Netherlands and the United States.
- Generally no, or not for staff placed with a client: Australia, Canada, Singapore and the United Kingdom.
- Only as a licensed agency, or only through specific permits: Germany (only where no Federal Employment Agency consent is needed), Spain and Portugal (licensed temporary work agencies) and the UAE (MOHRE permit types).
- Unclear: Ireland, where the 2021 policy and the 2024 Act point different ways.
- Why it can be restrictive: several countries' rules look for the employer that actually directs the work. An EOR employs the worker while the client directs it, which is the arrangement that agency and third-party rules target.
| Country | Can an EOR sponsor? | Key condition | Main route |
|---|---|---|---|
| Australia | Not as a standard sponsor | On-hire labour agreement needed | Skills in Demand visa (subclass 482), with the employer as sponsor |
| Canada | No (LMIA route) | Agencies recruiting for other businesses aren't employers | Employer-specific work permit, usually based on a Labour Market Impact Assessment (LMIA) |
| Germany | Only without BA consent | e.g. standard EU Blue Card; provider needs AÜG licence | EU Blue Card or skilled-worker residence permit (the worker applies; there is no sponsor licence) |
| Ireland | Unclear | 2021 policy says no; the 2024 Act provides for agency applications | Critical Skills or General Employment Permit (no sponsor licence) |
| Japan | Yes, as a licensed dispatcher | Dispatch licence; client fixed before applying | Engineer/Specialist in Humanities/International Services status (Certificate of Eligibility) |
| Netherlands | Yes, if registered | IND recognised sponsor and SNA register; Wtta admission from 2027 | Highly skilled migrant permit, applied for by an IND-recognised sponsor |
| Portugal | Only as a licensed agency | Temporary work agency licence; temporary placements only | Residence visa and permit for subordinate work (no sponsor licence) |
| Singapore | Not to supply staff | Only to deliver the employer's own services, under its supervision | Employment Pass or S Pass, applied for by the employer |
| Spain | Only as a licensed ETT | ETT authorisation; route-specific limits | Highly qualified professional permit (Ley 14/2013) or employee work permit (RD 1155/2024) |
| United Arab Emirates | Only via MOHRE permit types | Temporary or part-time permits, or a MOHRE-licensed agency | MOHRE work permit and residence visa, held by the employer |
| United Kingdom | No | The client must hold the sponsor licence | Skilled Worker visa, with a Certificate of Sponsorship from a licensed sponsor |
| United States | H-1B: yes. L-1: no | Bona fide job offer; client's role judged on the client's requirements | H-1B (employer petition) or L-1 (intracompany transfer) |
- Short answer: Not as a standard sponsor.
- Visa or permit: Skills in Demand visa (subclass 482), with the employer as sponsor.
- A standard business sponsor must employ the worker itself or through an associated entity, in its own business, and must not recruit or hire out the visa holder to a business it isn't associated with (Migration Regulations regs 2.72(11), 2.73(14) and 2.86(2AA)).
- Placing sponsored workers with clients is "on-hire". The official route is an On-hire labour agreement: the sponsor pays the worker itself, holds a contract with each client, monitors the client's workplace compliance, and may not leave the worker without work ("benching is not permitted").
- A short list of occupations, such as chief executive and some medical roles, is exempt from the requirement to work in the sponsor's own business.
- More on employing there: Australia.
- Short answer: No, for LMIA-based permits.
- Visa or permit: Employer-specific work permit, usually based on a Labour Market Impact Assessment (LMIA).
- Since 18 September 2026, the Temporary Foreign Worker Program defines the employer as "the entity that hires the temporary foreign worker, sets their working conditions and directly pays them", and says staffing or employment agencies that recruit workers for other businesses "aren't considered employers" and can't be approved to hire for those businesses (ESDC).
- Service Canada looks at who benefits from the work and who controls where, when and how it's done, among other factors. Most work permits are tied to one employer, and changing employer needs a new permit (IRCC).
- More on employing there: Canada.
- Short answer: Only where no Federal Employment Agency consent is needed.
- Visa or permit: EU Blue Card or skilled-worker residence permit (the worker applies; there is no sponsor licence).
- A worker placed with a client who integrates them and gives the instructions is on loan under the AÜG, and the provider needs a labour-leasing licence (AÜG § 1(1)).
- Where the Federal Employment Agency (BA) must consent to the employment, it must refuse if the foreigner will work as a temporary agency worker (AufenthG § 40(1) no. 2), with no discretion.
- The BA's guidance says agency work is allowed where no consent is needed, for example the standard EU Blue Card, which is issued without BA consent (§ 18g(1)). The lower-salary Blue Card for shortage occupations and recent graduates, and the skilled-worker permit under § 18b, need consent.
- More on employing there: Germany.
- Short answer: Unclear.
- Visa or permit: Critical Skills or General Employment Permit (no sponsor licence).
- The Department of Enterprise's published policy says permits "cannot be considered from an employment agency" where the worker is assigned to work for, and under the direction of, another employer, and the General Employment Permit requires the worker to be employed, salaried and paid directly by the employer.
- But that policy page dates from 2021 and relies on the repealed 2006 Act. The Employment Permits Act 2024 includes contracts with an employment agency to work for a third person in its definition of a contract of employment, and says the application is then made by the agency (ss. 2(1) and 12(2)). Until the Department updates its guidance, ask it directly.
- More on employing there: Ireland.
- Short answer: Yes, as a licensed dispatcher.
- Visa or permit: Engineer/Specialist in Humanities/International Services status (Certificate of Eligibility).
- The Immigration Services Agency accepts dispatch (haken) for this status: the dispatching company is the accepting organisation, and both it and the client sign written pledges, with the individual dispatch contract submitted.
- The client must be fixed when the application is made, the period of stay follows the dispatch contract, and the agency may check directly with the client.
- Having your own employee work under another company's direction is worker dispatch, which requires a licence from the Minister of Health, Labour and Welfare (Worker Dispatching Act arts. 2 and 5).
- More on employing there: Japan.
- Short answer: Yes, if registered.
- Visa or permit: Highly skilled migrant permit, applied for by an IND-recognised sponsor.
- Only an employer recognised by the IND can apply for a highly skilled migrant permit. A business that supplies workers or provides payrolling can be recognised only if it is listed in the register of the Labour Standards Foundation (SNA) (Voorschrift Vreemdelingen 2000 art. 1.14).
- Labour suppliers must also be registered as such in the trade register (Waadi art. 7a), and from 1 January 2027 they need official admission under the new Wtta regime.
- More on employing there: Netherlands.
- Short answer: Only as a licensed temporary work agency.
- Visa or permit: Residence visa and permit for subordinate work (no sponsor licence).
- The general route needs an employment contract (or promise of one) and social security registration (Lei 23/2007 arts. 59 and 88). The holder can change employer by notifying AIMA, without a new permit.
- A company that supplies a worker to a user under the user's direction is a temporary work agency, which needs a licence; contracts by an unlicensed agency are void (Labour Code arts. 172–173). Temporary agency work is allowed only in listed temporary situations, for at most two years (arts. 175 and 178).
- Workers contracted through agencies that place people under someone else's direction are excluded from the intra-company transfer permit (Lei 23/2007 art. 124-A).
- More on employing there: Portugal.
- Short answer: Not to supply staff.
- Visa or permit: Employment Pass or S Pass, applied for by the employer.
- The Ministry of Manpower lets an employer deploy pass holders to a client's premises only to provide its own services under a contract for service, where the work matches the pass and the company's declared business, and the company "remains as the employer, and directly supervises the work" and pays the salaries.
- Deploying pass holders to a client "for the sole purpose of supplementing its workforce" isn't allowed, except under conditions in the construction and process sectors. A company not registered in Singapore needs a local sponsor to apply for an Employment Pass for its own employee.
- More on employing there: Singapore.
- Short answer: Only as a licensed temporary work agency.
- Visa or permit: Highly qualified professional permit (Ley 14/2013) or employee work permit (RD 1155/2024).
- Hiring workers to place them temporarily with another company is allowed only through duly authorised temporary work agencies (ETTs); otherwise it is illegal labour supply (Workers' Statute art. 43). ETT authorisation requires the business to be dedicated exclusively to that activity (Ley 14/1994 art. 2).
- The immigration regulation bars ETTs from collective recruitment at origin (RD 1155/2024 art. 121.2); its bar on ETTs holding seasonal permits was annulled by the Supreme Court on 8 July 2026. The highly qualified professional route is filed by the company that needs the professional, and says nothing either way about ETTs.
- More on employing there: Spain.
- Short answer: Only through MOHRE's own mechanisms.
- Visa or permit: MOHRE work permit and residence visa, held by the employer.
- Nobody may work in the UAE, and no employer may employ a worker, without a work permit from the Ministry of Human Resources and Emiratisation (Decree-Law 33/2021 art. 6), and the occupation must match the establishment's business activity.
- The employer must not let the worker work for others except as the law provides (art. 13). MOHRE permit types cover some cases, such as a temporary permit to assign a worker to another company for a limited period, or a part-time permit with MOHRE approval. MOHRE licenses recruitment agencies, for UAE citizens only.
- More on employing there: United Arab Emirates.
- Short answer: No.
- Visa or permit: Skilled Worker visa, with a Certificate of Sponsorship from a licensed sponsor.
- The Immigration Rules don't allow a Skilled Worker job that amounts to hiring the worker out to a third party to fill a position there, or to provide an ongoing routine role or service for a third party (Appendix Skilled Worker SW 5.6).
- The Home Office says the sponsor must be whoever has full responsibility for the duties and outputs of the job. An employment agency or other intermediary can hold a licence only to sponsor workers employed directly in running its own business; sponsoring a worker and supplying them to another organisation leads to the licence being revoked (sponsor guidance L5.12–L5.13, S1.34–S1.38).
- The client itself can sponsor, if it decides the job's duties and outputs and is responsible for agreeing and paying the worker's salary (L5.14).
- More on employing there: United Kingdom.
- Short answer: H-1B: yes. L-1: no.
- Visa or permit: H-1B (employer petition) or L-1 (intracompany transfer).
- Since January 2025, the H-1B petitioner must be a United States employer with a bona fide job offer, a legal presence in the US and a tax ID; the old employer-employee relationship test was removed (8 CFR 214.2(h)(4)(ii); final rule of 18 December 2024).
- The rules expressly cover workers "staffed to a third party": the third party's requirements decide whether the role is a specialty occupation, USCIS may ask for the contracts between all parties, and refusing a site visit at a third-party worksite can lead to denial or revocation.
- The L-1 needs a qualifying relationship (parent, branch, affiliate or subsidiary) between the US employer and the worker's foreign employer, so an unrelated EOR can't use it for a client's transferee (8 CFR 214.2(l)(1)(ii)(G)).
- Ask the provider which entity will sponsor, and under which route. In several countries the honest answer is that the EOR can't, or only under a specific licence or agreement.
- Check whether your own company would need to be the sponsor. In the UK, for example, the client has to hold the sponsor licence for a placed worker.
- Look at the labour-hire rules too. The same arrangement that limits visa sponsorship can also trigger labour-hire licensing or time limits; see where EOR counts as labour hire.
- Consider your own entity for long-term visa hires. See foreign subsidiary vs EOR.
Can an employer of record sponsor a UK Skilled Worker visa?
Can an EOR sponsor an H-1B visa?
Can an EOR sponsor a visa in Australia?
Can an EOR sponsor an Employment Pass in Singapore?
Can a staffing agency get an LMIA in Canada?
Can an EOR be a recognised sponsor in the Netherlands?
Can an EOR sponsor a German EU Blue Card?
- 1Migration Regulations 1994 (Compilation No. 289, 2 October 2026)
Federal Register of Legislation
Regs 2.72(5) and (11), 2.73(14)–(14A), 2.86(2AA) and (2A).
- 2Labour agreement template: on-hire industry
Department of Home Affairs
On-hire defined; payment by the sponsor, client contracts, compliance monitoring, no benching.
- 3Exempt occupations (subclass 482)
Department of Home Affairs
Occupations exempt from working in the nominating employer's business.
- 4Program requirements for high-wage positions
Employment and Social Development Canada
Who is the employer under the TFW Program; staffing and employment agencies (modified 18 September 2026).
- 5Immigration and Refugee Protection Regulations, ss. 185, 200 and 203
Justice Laws Website
Work permit conditions by employer; genuine job offer; LMIA.
- 6Change jobs or employers
Immigration, Refugees and Citizenship Canada
A new permit is needed to change employer on an employer-specific permit.
- 7Aufenthaltsgesetz § 40 and § 18g
Bundesministerium der Justiz (gesetze-im-internet.de)
Consent must be refused for temporary agency workers; the standard Blue Card is issued without BA consent.
- 8Fachliche Weisungen AufenthG/BeschV (Stand 12/2024)
Bundesagentur für Arbeit
Marginal 40.0.2: the ban applies only where BA consent is required.
- 9Arbeitnehmerüberlassungsgesetz § 1
Bundesministerium der Justiz (gesetze-im-internet.de)
Labour leasing needs a licence; definition of leasing.
- 10Eligibility for employment permits for employment agencies and agency workers
Department of Enterprise, Tourism and Employment
Agency applications not considered where the worker works under another employer's direction (2021).
- 11General Employment Permit: employer criteria
Department of Enterprise, Tourism and Employment
The worker must be employed, salaried and paid directly by the employer.
- 12Employment Permits Act 2024 (revised)
Law Reform Commission (Revised Acts)
Ss. 2(1) and 12(2): contracts with an employment agency to work for a third person; applications by the agency.
- 13派遣形態で就労する場合の取扱いについて (July 2026)
Immigration Services Agency of Japan
Dispatch site must be fixed; period of stay follows the dispatch contract; checks with the client; pledges.
- 14在留資格「技術・人文知識・国際業務」
Immigration Services Agency of Japan
Documents for dispatched workers, including pledges from the dispatcher and the client.
- 15労働者派遣法 (Worker Dispatching Act) arts. 2 and 5
e-Gov法令検索
Definition of worker dispatch; licence from the Minister of Health, Labour and Welfare.
- 16Highly skilled migrant
Immigration and Naturalisation Service (IND)
Only an employer recognised by the IND can apply (updated 11 September 2026).
- 17Voorschrift Vreemdelingen 2000, art. 1.14
Overheid.nl (wetten.overheid.nl)
Labour suppliers and payrolling firms recognised only if on the SNA register.
- 18Wet allocatie arbeidskrachten door intermediairs (Waadi)
Overheid.nl (wetten.overheid.nl)
Art. 7a registration; chapter 3a admission (toelating) from 1 January 2027.
- 19Lei n.º 23/2007 (as amended by Lei n.º 62/2026)
Procuradoria-Geral Regional de Lisboa
Arts. 59, 88, 124-A and 198-A.
- 20Código do Trabalho, arts. 172–178
Procuradoria-Geral Regional de Lisboa
Temporary agency work: licence, permitted cases and duration.
- 21Am I allowed to send my work pass holders to work at my client's place?
Ministry of Manpower
Conditions for client-site deployment; supplying labour not allowed (updated 8 April 2026).
- 22Apply for an Employment Pass
Ministry of Manpower
Applications by the employer or an appointed agent; local sponsor for overseas companies (updated 15 June 2026).
- 23Estatuto de los Trabajadores, art. 43
Boletín Oficial del Estado
Labour supply only through authorised ETTs; illegal supply.
- 24Real Decreto 1155/2024 (Reglamento de Extranjería)
Boletín Oficial del Estado
Arts. 74, 101.1 (paragraph annulled 8 July 2026) and 121.2.
- 25Ley 14/2013, arts. 71 and 76
Boletín Oficial del Estado
Highly qualified professionals; processing by the Unidad de Grandes Empresas.
- 26Ley 14/1994 (empresas de trabajo temporal), art. 2
Boletín Oficial del Estado
Prior authorisation; exclusive dedication.
- 27Federal Decree-Law No. 33 of 2021 (unofficial English translation)
UAE Government portal (u.ae)
Arts. 6, 11, 13 and 60.
- 28Work permits
UAE Government portal (u.ae)
MOHRE's permit types, including temporary and part-time permits (updated 19 October 2026).
- 29Immigration Rules Appendix Skilled Worker
GOV.UK (Home Office)
SW 5.5–5.6: genuine vacancy; no hiring out to a third party (updated 8 October 2026).
- 30Workers and Temporary Workers: guidance for sponsors, Part 1 (version 08/26)
GOV.UK (Home Office)
L5.12–L5.14: agencies and intermediaries; client sponsorship of agency-supplied workers.
- 31Workers and Temporary Workers: guidance for sponsors, Part 2 (version 10/26)
GOV.UK (Home Office)
S1.34–S1.38: who must be the sponsor; third-party work; revocation.
- 328 CFR 214.2 (eCFR, 14 October 2026)
Electronic Code of Federal Regulations
H-1B: (h)(2)(i)(A), (h)(4)(i)(B)(2)–(3), (h)(4)(ii), (h)(4)(iv)(C); L-1: (l)(1)(ii)(G).
- 33Modernizing H-1B Requirements, final rule (89 FR 103054, 18 December 2024)
Federal Register (govinfo.gov)
Replaced the employer-employee relationship test with a bona fide job offer requirement; effective 17 January 2025.